1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION LUIS AGUILERA, ) ) Case No. 11 C 9241 Plaintiff, ) ) Jury Trial Demanded vs. ) ) CHICAGO PUBLIC SCHOOLS OF THE ) BOARD OF EDUCATION OF THE CITY OF ) CHICAGO, ) Defendant. ) COMPLAINT Plaintiff, LUIS AGUILERA, hereinafter “AGUILERA,” through his attorney, complains against Defendant, CHICAGO PUBLIC SCHOOLS OF THE BOARD OF EDUCATION OF THE CITY OF CHICAGO, hereinafter “BOARD,” as follows: I. NATURE OF ACTION 1. This is an action brought against Defendant under 42 U.S.C. Section 1983, 28 U.S.C. Section 1331 and 1337, the 1964 and 1991 Civil Rights Acts, and the Constitution of the United States of America, to recover actual damages caused by Defendant’s discrimination and retaliation against the Plaintiff, arising out of Plaintiff’s speech, for an award of punitive damages, injunctive relief, and for such other relief as this Court deems proper, including, but not limited to, an award of attorneys’ fees under 42 U.S.C. § 1988. . Plaintiff demands trial by jury. II. JURISDICTION AND VENUE 2. This Court has jurisdiction pursuant to 28 U.S.C. § 1331 and § 1343. 3. Venue is appropriate under 28 U.S.C. § 1391, because the Defendant conducts
This is an action brought against Defendant under 42 U.S.C. Section 1983, 28U.S.C. Section 1331 and 1337, the 1964 and 1991 Civil Rights Acts, and the Constitution of theUnited States of America, to recover actual damages caused by Defendant’s discrimination andretaliation against the Plaintiff, arising out of Plaintiff’s speech, for an award of punitivedamages, injunctive relief, and for such other relief as this Court deems proper, including, butnot limited to, an award of attorneys’ fees under 42 U.S.C. § 1988. . Plaintiff demands trial byjury.
